Memorandum Findings of Fact and Opinion
PARKER, Judge.
Pursuant to a notice of transferee liability, respondent determined that petitioner is liable for unpaid Federal income taxes in the amount of $291,645, plus interest, as the transferee of assets of James Williamson (James) and Vera Williamson (Vera). James and Vera are sometimes hereinafter referred to as the transferors.
Unless otherwise indicated, all section references are to the Internal...
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